The short version. We collect very little: your email, your first name if you give it, and a few details about how you found us. We use it to hold your place for an invitation to Confidely and to email you about your invitation and Confidely’s launch, as you agree when you sign up. We never sell it and never use it for advertising. Analytics only runs if you say yes, and you can turn it off. You can ask us to delete your information at any time by writing to [email protected].
Who we are
This website, getconfidely.com, is run by Sphaera Nova Technologies, Inc. (“Confidely”, “we”, “us”), a Delaware corporation, at 2810 North Church Street, Wilmington, DE 19802, United States.
We decide how and why your information is used, which makes us the “controller” (in the EU and UK) or “personal information controller” (in the Philippines) for it.
- Privacy questions and requests: [email protected]
- Data Protection Officer (also our person in charge of the protection of personal information under Quebec law): [email protected]
What this policy covers
This policy covers the Confidely website, the invitation waitlist, and the emails we send about your invitation and Confidely’s launch.
We’re launching Confidely in Southeast Asia. This website can be reached from anywhere, though. Wherever you are, this policy applies to you, together with any extra rights the law where you live gives you (see “Your rights”).
It doesn’t cover the Confidely app. The app handles very different information, including your conversations with Anya, and has its own privacy policy that you’ll see and agree to before you use it.
What we collect
What you give us
- Your email address. Required to join the waitlist.
- Your first name. Optional. We use it to greet you.
- Your agreement. When you ticked the box confirming you’re 18 or older, that you agree to our Terms of Use and to be contacted by email about your invitation and Confidely’s launch, and which versions of the Terms and this policy you saw.
- Anything you write to us. If you email us, we keep the email and our reply.
Please don’t include anything sensitive, such as details about your health or feelings, in the name field or in emails to us. We don’t need it.
What we collect automatically
- Your country, and your state or province. Worked out by our security provider, Cloudflare, from your IP address. We use it to show the right cookie choices and to understand where interest comes from. We store the country with your sign-up, not your IP address or your state.
- How you found us. Which version of the home page you saw (we test a few), the invitation tag in the link you followed, if any (for example
?ref=invite), and the campaign tags in that link, if any (where it was posted, for exampleutm_source=reddit). - Your cookie choice. A record of what you chose, explained in “Cookies and analytics” below.
- Analytics. How you use the site, through Google Analytics, explained in “Cookies and analytics” below.
- Security logs. Like almost every website, our servers and Cloudflare record technical details of each request: IP address, date and time, the page requested, browser type, and the website that sent you. We use these only to keep the site running and secure, for example to block attacks and spam sign-ups.
What we don’t collect
We don’t collect payment details, your precise location, your contacts, or information about your health on this website. We don’t buy information about you from anyone, and we don’t combine what you give us with information from data brokers or social networks.
How we use it, and why we’re allowed to
| What we do | Information used | Our legal basis (EU and UK GDPR) |
|---|---|---|
| Keep your place on the waitlist, send your invitation, and tell you about changes to it | Email, first name, sign-up date, country | To do what you asked us to under our Terms of Use (Art. 6(1)(b)) |
| Email you about Confidely’s launch | Email, first name | Your agreement to be contacted when you signed up (Art. 6(1)(a)). Unsubscribe any time |
| Understand which page version and which links bring people to Confidely | Page version, invitation tag, country | Our legitimate interest in improving how we explain Confidely (Art. 6(1)(f)) |
| Website analytics, only if you allow it | See “Cookies and analytics” | Your consent (Art. 6(1)(a)) |
| Keep the site and your information secure, stop spam and abuse | Security logs, IP address (held briefly), sign-up details | Our legitimate interest in protecting the site and the people on our list (Art. 6(1)(f)) |
| Keep records showing you agreed and what you chose | Agreement time and versions, cookie choice records | Our legal obligation to be able to show consent (Art. 6(1)(c) and 7(1)) |
| Answer your questions and requests | Your emails | To respond to you (Art. 6(1)(b)), and our legal obligations for rights requests (Art. 6(1)(c)) |
| Comply with the law, enforce our Terms, and protect our rights | What’s needed for the purpose | Legal obligation (Art. 6(1)(c)) and legitimate interests (Art. 6(1)(f)) |
The Philippine Data Privacy Act applies when we handle information about people in the Philippines. Under it, we rely on the matching grounds in Section 12: your consent, what’s needed for our agreement with you, compliance with the law, and our legitimate interests.
Where we rely on legitimate interests, we’ve weighed them against your rights, and you can object at any time (see “Your rights”).
We never sell your information. We never use it for advertising, never share it for targeted advertising, and never use it to train AI models.
Who we share it with
We share information only with providers that help us run the site, under contracts that require them to protect it and limit how they can use it:
| Provider | What they do for us | Where |
|---|---|---|
| Akamai Technologies (Linode) | Hosts our server and database | Singapore |
| Cloudflare, Inc. | Delivers the site securely, blocks attacks and spam, tells us your country | Global network; company based in the United States |
| Google LLC | Google Analytics and Google Tag Manager, where analytics is on | United States and other countries |
| Zoho Corporation | Our email: sends our emails to you and receives yours | United States |
We may also share information:
- When the law requires it, for example a valid court order, and only what’s required.
- To protect people, if we believe in good faith that it’s needed to prevent serious harm.
- To protect our rights, with our professional advisers (such as lawyers and accountants), who must keep it confidential.
- If our business changes hands, for example in a merger or sale. The new owner would have to respect this policy, and we’d tell you before your information became subject to a different one.
Where your information goes
We’re a US company, our server is in Singapore, and our team and providers work in other countries too. So your information may be handled in countries other than your own, which may have different data protection laws. Those countries are the United States, Singapore and the Philippines, plus the countries where Cloudflare runs data centers (close to wherever you are when you visit).
When we transfer information out of the European Economic Area, the UK or Switzerland, we use the safeguards the law provides: the European Commission’s standard contractual clauses (and their UK and Swiss versions), or a provider’s certification under the EU-US Data Privacy Framework and its UK and Swiss extensions where it applies. Under the Philippine Data Privacy Act, we remain responsible for your information wherever it goes. You can ask us for a copy of the relevant safeguards at [email protected].
How long we keep it
| Information | How long |
|---|---|
| Your waitlist entry | Until the Confidely app is generally available. We delete the waitlist within 30 days of launch, once invitations have gone out, or sooner if you ask. If you join the app, the app’s privacy policy takes over |
| Do-not-send list | If you unsubscribe, we keep only your email on a do-not-send list, for as long as we send emails, so we don’t write to you again by mistake |
| Your agreement records (when you agreed, and to which versions) | As long as your waitlist entry |
| Cookie choice records | 2 years |
| Google Analytics data | 14 months for event-level data; reports that only show totals may be kept longer |
| Security logs on our server | Up to 14 days |
| IP addresses and emails used for spam limits | In memory only, usually for less than an hour (IP addresses also appear in security logs, above) |
| Backups | Up to 14 days, then overwritten |
| Emails with us | Up to 2 years after your request is closed, unless the law requires longer |
Your rights
You can, at any time and for free:
- See the information we hold about you, and get a copy.
- Correct anything that’s wrong.
- Delete your information. We’ll remove you from the waitlist. We keep only what we must: your email on a do-not-send list if you’d unsubscribed from our emails, so we never write to you by mistake, and backups, which are overwritten within 14 days.
- Take it with you, in a common format.
- Object to how we use it, or ask us to limit how we use it.
- Withdraw your consent, for example to being contacted, or to analytics. This doesn’t affect anything we did before.
- Complain to a data protection authority (listed below). We’d appreciate the chance to put things right first.
How to ask. Email [email protected] from the address you signed up with. If you write from another address, we may ask you to confirm you own the one on our list, so we never give your information to someone else. You can also ask someone to act for you, with your written permission. We’ll reply within one month (45 days for requests under US state laws), and tell you if we need longer and why.
Unsubscribing. Every email has an unsubscribe link. We act on it straight away, and always within 10 business days. Unsubscribing stops our emails; to leave the waitlist completely, ask us to delete your information.
If you’re in the Philippines
Under the Data Privacy Act of 2012 you have the right to be informed, to object, to access, to correct, to erasure or blocking, to data portability, to be indemnified for damages, and to file a complaint with the National Privacy Commission.
If you’re in the EU, the EEA, the UK or Switzerland
You have all the rights above under the GDPR, the UK GDPR or the Swiss Federal Act on Data Protection. You can complain to the data protection authority where you live or work, or where you think a problem happened: in the UK the Information Commissioner’s Office, in Switzerland the Federal Data Protection and Information Commissioner, and in the EU your national authority.
If you’re in the United States
Some state laws, such as California’s, give you specific rights. We give them to everyone, whether or not those laws apply to us yet.
- What we collect (in the terms those laws use): identifiers (email, first name); internet activity (analytics and security logs); and general location (country or province, never precise location). We collect these from you, from your browser, and from Cloudflare, for the purposes in “How we use it”, and keep them for the periods in “How long we keep it”.
- No selling or sharing. We don’t sell personal information or share it for cross-context behavioral advertising, and haven’t in the past 12 months. We don’t use sensitive personal information to infer anything about you.
- Your rights: to know, access, correct and delete your information, to opt out of selling and sharing (we don’t do either), and to not be treated differently for using these rights. To use them, email [email protected]. If we say no, you can appeal by replying to our answer, and if you’re still unhappy, contact your state attorney general.
- Global Privacy Control. If your browser sends a GPC signal, we treat it as a request to opt out and turn analytics off, even if you said yes earlier. The only exception is if you turn analytics back on yourself in Cookie settings.
- Do Not Track. There’s no agreed standard for “Do Not Track” signals, so we don’t respond to them. We do respond to Global Privacy Control.
Consumer health data (Washington, Nevada, Connecticut and similar laws). We don’t collect health information on this website, and we don’t consider joining the waitlist to be consumer health data. We don’t ask about your health, feelings or wellbeing, and we don’t use anything you give us to infer anything about your health. Analytics stays off unless you turn it on. The Confidely app, which you may choose to use later, has its own privacy policy that explains how it handles anything you share in it.
If you’re in Canada
You have the right to access and correct your information and to withdraw consent, under Canada’s privacy law (PIPEDA) and, in Quebec, Law 25. You can complain to the Office of the Privacy Commissioner of Canada or, in Quebec, the Commission d’accès à l’information.
If you’re elsewhere in Southeast Asia
Data protection laws in Singapore, Malaysia, Thailand, Indonesia and Vietnam give you rights to know what we hold about you, to correct it, to withdraw your consent, and in most cases to have it deleted. Use them as described above. You can also complain to your national data protection authority, for example Singapore’s Personal Data Protection Commission or Thailand’s Personal Data Protection Committee.
If you’re in Australia
You can access and correct your information under the Australian Privacy Principles. Some of it is handled outside Australia, as described in “Where your information goes”. If you’re not happy with our answer to a complaint, you can contact the Office of the Australian Information Commissioner.
Cookies and analytics
This website uses as few cookies as it can. Here’s every one, what it does, and how long it stays.
| Cookie | Type | What it does | How long |
|---|---|---|---|
confidely_consent | Necessary | Remembers your cookie choice, so we don’t ask on every visit. Holds your choice, the date, and a random code with no link to who you are | 6 months |
__cf_bm, cf_clearance | Necessary, set by Cloudflare | Tell people apart from automated traffic, to protect the site and the waitlist from bots | 30 minutes (__cf_bm); 30 minutes, Cloudflare’s default (cf_clearance), only if you’re asked to complete a check |
_ga | Analytics | Set by Google Analytics to tell visits apart | Up to 2 years |
_ga_<id> | Analytics | Set by Google Analytics to keep track of a visit | Up to 2 years |
We don’t use advertising cookies.
Analytics
We use Google Analytics, through Google Tag Manager, to understand how people find and use this website: for example how many people visit, which links brought them here, and how many ask for an invitation. Google Analytics collects the pages you view, the link you came from, your approximate location (worked out from your IP address, which Google Analytics doesn’t keep), and your device and browser type. We never send Google your name, your email address or anything you type into this site. Google processes this data for us under its data processing terms and may process it in the United States. Google keeps event-level data for 14 months, then deletes it; reports that only show totals may be kept longer. We’ve turned off Google’s advertising features (Google signals). If your browser sends a Global Privacy Control signal, analytics stays off unless you turn it on yourself in Cookie settings.
Analytics is off until you say yes. Wherever you are, Google Analytics isn’t loaded at all until you choose Allow analytics. You can turn it off again at any time in Cookie settings.
Changing your choice
Choose Cookie settings at the bottom of any page. If you turn analytics off, we delete the Google Analytics cookies from your browser. You can also block or delete cookies in your browser settings; the site still works without them.
Record of your choice
When you make a choice, we keep a record of it: the random code from the confidely_consent cookie, your choice, the version of the notice you saw, your country and state or province, and the date. This lets us show we asked properly. It doesn’t include your IP address, your name or your email.
Emails
When you join the waitlist, you agree that we can email you about your invitation, your place on the waitlist and Confidely’s launch. We won’t send you anything else, such as a newsletter, unless you separately ask for it. Our first email asks you to confirm your address, so nobody is signed up without knowing; if you don’t confirm, we won’t email you again. Every email includes our postal address and a link to unsubscribe.
Age
Confidely is only for people 18 and older, and this website isn’t meant for anyone younger. We don’t knowingly collect information from anyone under 18. If you think someone under 18 has signed up, tell us at [email protected] and we’ll delete their information.
How we protect your information
- Everything between your browser and us is encrypted in transit (HTTPS).
- Our server accepts web traffic only through Cloudflare and sits behind a firewall. Access to the server is limited to named team members.
- The database is stored outside the website’s public files with restricted file permissions. Emails are never written to our logs.
- Backups are encrypted.
- Only the people who need it to run the waitlist can see it.
No system is perfectly secure. If a breach is likely to cause you serious harm, we’ll tell you and the authorities as the law requires, including under US state breach notification laws and, for people in the Philippines, by notifying the National Privacy Commission within 72 hours of learning of it.
Decisions about you
We don’t make decisions about you by automated means that have legal or similarly significant effects. Who gets invited, and when, is decided by people, mostly by sign-up order and how many people we can welcome at a time.
Changes to this policy
We’ll update this policy when what we do changes. The version and effective date are at the top. If a change matters to how we use your information, we’ll email you before it takes effect, and ask for your consent again where the law requires it.
Contact us
Sphaera Nova Technologies, Inc., 2810 North Church Street, Wilmington, DE 19802, United States
Email: [email protected]
Phone: +1 302 208 8598
Data Protection Officer: [email protected]